Jewett v. Warden, Noble Correctional Institution

District Court, S.D. Ohio·Decided March 21, 2025·No. 1:18-cv-00406·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT CINCINNATI

TYRONE JEWETT,

Petitioner, : Case No. 1:18-cv-406

- vs - District Judge Jeffery P. Hopkins Magistrate Judge Michael R. Merz

WARDEN, Noble Correctional Institution,

: Respondent. SUPPLEMENTAL REPORT AND RECOMMENDATIONS

This is a habeas corpus case brought pro se by Petitioner Tyrone Jewett under 28 U.S.C. § 2254. Jewett seeks relief from his convictions in the Scioto County Court of Common Pleas (Petition, ECF No. 1). On February 21, 2025, the undersigned filed a Report and Recommendations (the “Report,” ECF No. 45). Petitioner has objected (the “Objections,” ECF No. 46) and District Judge Hopkins has recommitted the case pursuant to Fed.R.Civ.P. 72(b)(3) for consideration of the Objections (Order, ECF No. 47). This case is before the Court only on the claims made in the Amended Petition (ECF No. 34). The Court has already ordered the claims made in the original Petition to be dismissed, but has not yet entered judgment, having stayed the case to permit Petition to exhaust in state court the claims made in his Amended Petition (ECF No. 16). Litigation History Regarding Claims Made in the Amended Petition

On July 12, 2023, Petitioner moved to lift the stay and to allow him to amend the Petition (ECF No. 32). He did not attach a proposed amended petition, but indicated he wished to raise claims of ineffective assistance of appellate counsel and denial of due process because he was tried

by an incapacitated judge. Id. at PageID 2049. Magistrate Judge (now Chief Magistrate Judge) Stephanie Bowman recommended granting that unopposed motion (Report and Recommendations, ECF No. 33). Her Report refers only to the due process impaired judge claim, and not any ineffective assistance of appellate counsel claim. Id. at PageID 2053-54. Judge Bowman’s Report was filed on May 2, 2024. Without waiting for Judge Hopkins to adopt the Report, Petitioner filed his Amended Petition on June 27, 2024, as if permission to file had already been granted rather than merely recommended. Judge Hopkins adopted that recommendation and set an answer date of October 10, 2024 (ECF No. 36). On that date, Respondent filed a return to the Amended Petition (ECF No. 39). A month

later, Petitioner moved for leave to file a traverse instanter and for supplementation of the record (ECF No. 40). That Motion was still pending when the Magistrate Judge reference in the case was transferred to the undersigned on February 14, 2025 (ECF No. 41). The undersigned then granted the pending Motion the same day (ECF No. 42) and Petitioner’s Traverse was separately docketed (ECF No. 43). That was the state of the docket when the undersigned filed the Report.

The Report and Objections

The Amended Petition pleads two Grounds for Relief: Ground One: Petitioner suffers denial of due process and right to a fair trial pursuant to the prejudice suffered from a trial before an incapacitated judge and failure of the mechanism designed to correct such.

Ground Two: The consecutive sentences imposed below fail the Eighth Amendment disproportionality test and/or violate the Fifth Amendment prohibition against multiple punishments for the same offense.

(ECF No. 34, PageID 2063, 2066). Ground One is the claim on which the stay was granted. Ground Two was brought into this case only with the Amended Petition. The Court has jurisdiction to consider Ground Two despite the prohibition on second and successive habeas petitions in 28 U.S.C. § 2244(b) because no judgment was entered as yet as to the original Petition. Even a new habeas case filed while a prior one is pending is not second or successive, but is to be treated as a motion to amend. In re: David Barron, Case No. 24-3474 (6th Cir. Feb. 5, 2025), citing In re Stevenson, 889 F.3d 308, 309 (6th Cir. 2018).

Statute of Limitations

In the Return to the Amended Petition, Respondent asserted both grounds for relief made in the Amended Petition were barred by the statute of limitations which is codified at 28 U.S.C. § 2244(d). The Report agreed that the new claims did not relate back to the date of the original claims because the new claims did not arise from a “common core of operative facts” with the original claims, as required for relation back under Fed.R.Civ.P. 15. Report, ECF No. 45, PageID 2352, citing Cowan v. Stovall, 645 F.3d 815, 818 (6th Cir. 2011)(quoting Mayle v. Felix, 545 U.S. at 650). Petitioner objects: The Magistrate also perceives Ground One of Amended Petition to be barred by the statute of limitations based upon not "relating back" to a "common core of operative facts", but he is misplaced here. The original petition raised three (3) against the state trial court that involved the judge's rulings and legal basis for jury instructions. Clearly, the trial judge's incapacitation relates back to these competency issues and are subject to a motion for new trial under Ohio Crim. R. 33. Therefore, Ground One "relates back" to the original, timely petition and the Court of Appeals' decision violated clearly established Federal law. Williams v. Taylor, 529 U. S. 420, 435 (2000)(the inquiry is not whether the facts could have been discovered but whether the prisoner was diligent in his efforts. Diligence depends upon whether the prisoner made a reasonable attempt, in light of the information available at the time, to investigate and pursue claims in state court). Petitioner was clearly diligent in bringing claim before this Court for its corrective powers.

(Objections, ECF No. 46, PageID 2359, emphasis supplied). This objection misunderstands the relation back rule which speaks to the question whether there is a common core of facts. The claims that the trial judge committed legal, indeed constitutional, error in his rulings in no way depended upon asserting he was incapacitated by alcohol and no such assertion was made (See Report and Recommendation, ECF No. 1, PageID 5-9). The question under Fed.R.Civ.P. 15(c) is not how diligent a petitioner was in gathering facts, but whether the facts gathered are part of the same “common core” of facts with original claims. The Report also concluded the facts underlying Ground Two, ineffective assistance of appellate counsel, were not part of a common core of operative facts with the original claims. Petitioner makes no objection on this point and none would have merit. An ineffective assistance of appellate counsel claim relates entirely to what appellate counsel did, not any incapacity or other failing of the trial judge. The Report analyzed the statute of limitations question under 28 U.S.C. § 2244(d)(1)(A) (Report, ECF No. 45, PageID 2351-52). The Report also analyzed the possibility that Petitioner would rely on 298 U.S.C. § 2244(d)(1)(D), but rejected any such claim. Id. at PageID 2352-55. Petitioner makes no objection to that analysis and thus has waived any opportunity for doing so.

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Jewett v. Warden, Noble Correctional Institution, (S.D. Ohio 2025).

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